Kahuna Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Kahuna Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.
Kahuna Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Kahuna Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Kahuna Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Kahuna Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
1. App Providers
How do we collect and use information from App Providers?
Our goal in collecting information is to provide and improve the Kahuna Service, to administer your Account, and to enable you to enjoy and easily navigate the Kahuna Service.
When you, as an App Provider, create an Account or when you request information about the Kahuna Service, we’ll collect certain information that can be used to identify you (“Personally Identifiable Information” or “PII”), such as your name, email address, phone number, and job title. We may also collect information that cannot be used to identify you, such as Account preferences.
Information Related to Use of the Site
We gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or Site functionality.
Modifying and Deleting Your Information
Upon request, Kahuna will provide you with information about whether we hold, any of your personal information. To request this information, please contact us at email@example.com.
You can access and modify the PII associated with your Account by accessing the user settings in the Kahuna Service. If you want us to delete your PII and your Account, please contact us at firstname.lastname@example.org with your request. We will respond to your request to access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you wish to subscribe to any newsletter(s) we may provide, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails and accessing the email preferences in your account settings page, or you can contact us at email@example.com.
You can connect your Facebook account with the Kahuna Service. These services will authenticate your identity and provide you the option to share with us certain PII, such as your name and email address to pre-populate our sign-up form.
2. End Users
How do we collect and use information from End Users?
When an App Provider embeds our tracking code into its Applications, we may access or obtain certain information that can be used to identify an End User (“Personally Identifiable Information” or “PII”) such as an End User’s email address, name and phone number, depending on the selections the applicable App Provider makes via the Kahuna Service.
We also access or obtain certain non-identifying information about End Users’ use of App Providers’ Applications and End Users’ devices, such as: the actions taken, content viewed, messages viewed, messages clicked, offers accepted, search terms entered, advertisements clicked, applications opened, applications sent to the background, transactions in which an End User engaged, application name, application version, application bundle identifier, operating system name, operating system version, unique device identifiers, and access date, time and location information.
We analyze and use this information for the limited purpose of providing and improving the Kahuna Service to App Providers.
Kahuna collects information under the direction of our App Providers, and has no direct relationship with the End Users whose personal data it processes. If you are a customer of one of our App Providers and would no longer like to be contacted by one of our App Providers that use the Kahuna Service, please contact the App Provider directly. An End User who seeks access to, or who seeks to correct, amend, or delete inaccuracies in his/her PII should direct his/her query to the appropriate App Provider (the data controller). If the App Provider requests that Kahuna remove all or a portion of the End Users’ PII, we will respond within 30 days.
How long do we retain information collected from End Users?
We will retain personal data we process on behalf of our App Providers for as long as needed to provide services to our App Providers. Kahuna will also retain this PII as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The following applies to both App Providers and End Users.
What App Provider and End User Information Do We Share With Third Parties?
Information Shared with Our Service Providers
We may engage third party service providers to work with us to administer and provide the Kahuna Service such as sending you email. These third-party Service providers have access to PII only for the purpose of performing the Kahuna Service on our behalf and are expressly obligated not to disclose or use your PII for any other purpose. Transfers to subsequent third parties are covered by the service agreements with our App Providers.
Information Shared with Third Parties
We may share aggregated, non-identifying information with third parties for industry analysis, demographic profiling and other similar purposes. Only aggregate metrics across broad categories would be shared. Metrics around industry conversion and retention rates may be shared as well as platform and channel messaging effectiveness. We will not share the End User PII collected for one App Provider with an unrelated App Provider.
Information Disclosed in Connection with Business Transactions
Information that we collect from App Providers and information that we receive about End Users, including PII, is considered to be a business asset. This means if we go out of business, enter bankruptcy, or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, such PII may be disclosed or transferred to the third-party acquirer in connection with the transaction. App Providers will be notified via email and/or a prominent notice on our Site of any change in ownership or use of PII, as well as any choices available regarding PII.
Information Disclosed for Our Protection and the Protection of Others
It is our policy to protect App Providers and End Users from having their privacy violated through abuse of the legal systems, whether by individuals, entities or government, and to contest claims that we believe to be invalid under applicable law. However, it is also our policy to cooperate with government and law enforcement officials and private parties. Accordingly, we reserve the right to disclose any information about App Providers or End Users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary: (i) to satisfy or comply with any law, regulation or legal process, or to respond to lawful requests, including subpoenas, warrants or court orders; (ii) to protect our property, rights and safety, and the rights, property and safety of third parties or the public in general; and (iii) to prevent or stop activity we consider to be illegal or unethical.
Information Collected Using Cookies and Tracking Technologies
Kahuna and our marketing partners and analytics providers use tracking technologies or similar technologies such as cookies, beacons, tags and scripts to analyze trends, administer the Site, track users’ movements around the Site, and gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and/or an aggregated basis.
Our third party partners use Local Storage (HTML5) to provide certain features on our Site to display advertising based on your web browsing activities, and/or to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.
We partner with third parties to display advertising on our Site or to manage our advertising on other websites. Our third party partners may use technologies such as cookies to gather information about your activities on this Site and other websites to provide you advertising based on your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt out by clicking here. If you are located in the European Union, click here. Please note this does not opt you out of being served ads; you will continue to receive generic ads.
The Security of Information
We take reasonable measures to protect the information that we collect from or receive about App Providers or End Users (including PII) from unauthorized access, use or disclosure. When you enter sensitive information (such as login credentials) on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL). Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) via email or conspicuous posting on our Site in the most expedient time possible and without unreasonable delay, insofar as they are consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Links to Other Sites
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Social Media Features
Information that we collect or receive may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide information to us, we may transfer your information to the United States and process it there (or any other country in which we operate).
Our Policy Toward Children
Our Kahuna Service is not directed to children under the age of 13 and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of a child under 13, we will take steps to delete such information from our files as soon as possible.
811 Hamilton Street
Redwood City, CA 94063
Last updated 1/15/2018